The purpose of Internal Revenue Code
(IRC) section 482 is to ensure taxpayers clearly reflect income
attributable to controlled transactions and to prevent avoidance of
taxes regarding such transactions. IRC section 482 places a
controlled taxpayer on a tax parity with an uncontrolled taxpayer
by determining true taxable income. Previously approved, TD 9568
(76 FR 80082) published December 22, 2011, contained final
regulations regarding methods to determine taxable income in
connection with a cost sharing arrangement under section 482 of the
Internal Revenue Code (Code). The final regulations address issues
that had arisen in administering the cost sharing regulations. The
final regulations affect domestic and foreign entities that enter
into cost sharing arrangements described in the final
regulations.
US Code:
26
USC 6103 Name of Law: Confidentiality and disclosure of returns
and return information
US Code: 26
USC 482 Name of Law: Allocation of income and deductions among
taxpayers
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.